PAIA Manual

This manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2000 for the Fynbos Group of Companies which includes Fynbos Arbitrage (Pty) Ltd, Fynbos Finance (Pty) Ltd, Fynbos Consulting (Pty) Ltd.

1. Introduction:

Welcome to the Promotion of Access to Information Act (PAIA) Manual of the Fynbos group of companies. This includes Fynbos Arbitrage (Pty) Ltd, Fynbos Finance (Pty) Ltd and Fynbos Consulting (Pty) Ltd. This manual outlines our commitment to transparency, access to information, and compliance with the PAIA legislation in the Republic of South Africa.

2. PAIA Overview:

The Promotion of Access to Information Act (Act No. 2 of 2000) promotes transparency and accountability by granting individuals the right to access information held by public and private bodies.

The Act sets out the procedural requirements attached to requests for information, the requirements which the requests for information must meet, as well as the grounds for refusing requests.

The Act recognises that the right to access information must be balanced with other rights and should be subject to limitations including, but not limited to, limitations aimed at the reasonable protection of privacy and commercial confidentiality.

3. Section 51 Manual:

This manual serves as our Section 51 Manual as required by PAIA. To obtain a physical copy, please contact our Information Officer using the contact details provided in Section 2.

4. Contact Information:

For all inquiries related to PAIA matters, please contact: Tarien Jacobs

Information Officer: Tarien Jacobs Address: Studio 02C, Brick Lane, Devonbosch, Bottelary Road, 7605 Email:

5. Guide on How to Use the Manual:

This manual is organized to help you understand how to request information and access records under the PAIA legislation. Please follow the provided sections to navigate through the information you seek.

6. Company Information:

The Fynbos group is a group of companies that specialises in lending, crypto arbitrage and tax consulting. The group is domiciled in South Africa and has been in operation since 2020.

7. Information Available in Terms of Other Legislation:

There are no other pieces of legislation that directly affect access to information in relation to our operations.

8. Categories of Records Held:

The Fynbos Group maintains a variety of records to support its operations, regulatory compliance, and interactions with stakeholders. These records are categorized as follows:

Financial Records: We maintain financial records that encompass the company's financial transactions, statements, reports, and audit documentation. These records include but are not limited to:

  • Income statements and balance sheets;
  • Bank statements and transaction records;
  • Invoices and receipts;
  • Tax records and filings;
  • Audited financial statements

Customer Data: As part of our business operations, we collect and process customer data. This category includes information provided by customers during registration, transactions, and communications. Customer data records may include:

  • Customer names and contact details;
  • Identification documents;
  • Transaction histories;
  • Communication logs;

Compliance Records: In compliance with relevant laws and regulations, we keep records that demonstrate our adherence to legal requirements and industry standards. This includes:

  • Anti-money laundering (AML) and know-your-customer (KYC) documentation
  • Compliance reports and assessments
  • Communication with regulatory bodies
  • Internal policies and procedures related to compliance

Communication Records: To ensure transparency and accountability, we maintain records of communications within the organization, with customers, partners, and regulatory authorities. This category includes:

  • Internal memos and emails
  • Customer communication history
  • Correspondence with regulatory bodies
  • Meeting minutes related to compliance and operations

Please note that access to certain records, particularly those containing sensitive customer information or proprietary trading strategies, may be subject to restrictions or redactions to protect privacy, confidentiality, and business interests. We are committed to providing access to information within the boundaries set by the Promotion of Access to Information Act.

Should you wish to request access to specific records within these categories, please follow the procedures outlined in Section 10 of this manual.

9. Records Automatically Available:

Certain records are available without the need for a formal request. These include publicly available information, marketing materials, and general company information.

10. Request Procedures:

At Fynbos, we are committed to upholding the principles of transparency and access to information as mandated by the Promotion of Access to Information Act (PAIA). If you wish to request access to specific information or records in our possession, please follow the procedures outlined below:

10.1 Submitting a Request:

To initiate an access to information request, kindly follow these steps:

Written Request: Prepare a written request for the information you seek. Your request can be in the form of a letter or email, addressed to the Information Officer (details provided in Section 2 of this manual).

Clearly Specify: Clearly state the nature and scope of the information you are requesting. Providing sufficient detail will help us process your request accurately. Please ensure that you provide the nature of the right that you are exercising or protecting.

Contact Information: Include your full contact details, including your name, postal address, email address, and contact number. This information will be used for communication regarding your request.

Fees: If applicable, consult the Fee Schedule (available upon request) to determine any fees or deposits required for processing your request. Attach proof of payment if applicable.

10.2 Processing of Requests:

Upon receiving your access to information request, we will take the following steps:

Acknowledgment: We will send you an acknowledgment of receipt within five working days of receiving your request. This acknowledgment will confirm that your request is being processed.

Processing Time: We will endeavor to provide you with the requested information within 30 days from the date of acknowledgment. If your request is complex or involves a large volume of records, we may extend this period by an additional 30 days, as allowed by PAIA.

10.3 Access or Refusal:

Once your request has been processed, we will provide you with the requested information or notify you of our decision to refuse access, if applicable. In cases of refusal, we will provide you with the reasons for the refusal, including the relevant sections of PAIA.

10.4 Grounds for Refusal:

Access to information may be refused under certain circumstances, as outlined in PAIA. These circumstances include, but are not limited to, protection of personal privacy, commercial confidentiality, and security considerations.

10.5 Fees and Deposits:

If applicable, any fees or deposits required for processing your request will be communicated to you before processing begins. These fees cover expenses such as search, preparation, and copying of records.

10.6 Appeals:

If you are dissatisfied with our response or the outcome of your request, you have the right to appeal. You can request an internal review of our decision, and if still unsatisfied, you can seek an external review through the Information Regulator.

11. Grounds for Refusal of Access:

Access to certain information may be refused in accordance with the provisions of the Promotion of Access to Information Act (PAIA). While we are committed to transparency and access to information, there are instances where refusal is necessary to safeguard various interests. The following are some of the grounds on which access may be refused:

11.1 Protection of Personal Privacy:

Access to information that contains personal and sensitive data about individuals, including borrowers, employees, and other stakeholders, may be refused if disclosure would infringe upon their right to privacy.

11.2 Commercial Confidentiality:

Information that is of a proprietary nature and would reveal trade secrets, commercial strategies, or confidential business relationships may be withheld to protect our competitive advantage and the interests of our borrowers.

11.3 Legal Privilege:

Information that is subject to legal privilege, such as attorney-client communications, may be withheld to ensure that legal advice and discussions remain confidential.

11.4 Security and Safety:

Access may be refused to information that, if disclosed, could compromise the security and safety of individuals, the organization, or the general public.

11.5 Ongoing Investigations and Legal Proceedings:

Information related to ongoing investigations, pending legal proceedings, or potential legal actions may be withheld to ensure that the integrity of these processes is maintained.

11.6 Information Provided in Confidence:

If information has been provided to us by a third party on a confidential basis, we may refuse access to such information to honor our commitment to confidentiality.

11.7 Prescribed by Law:

Access to information may be refused if it is prohibited by any other legislation or regulation.

12. Availability of the Manual:

This manual is available on our company website and can also be obtained in physical form by contacting our Information Officer.

13. Updates and Amendments:

This manual will be reviewed and updated as required by changes in legislation or company procedures. Any amendments will be communicated on our website and in the manual itself.